What is Coronavirus?
The World Health Organization defines coronaviruses as a family of viruses that cause infectious illness ranging from very mild to very severe diseases such as Middle East Respiratory Syndrome (MERS-CoV) and Severe Acute Respiratory Syndrome (SARS-CoV). Covid-19 is a new strain which originated in China at theend of 2019. It has since spread worldwide, initiating a global pandemic publichealth emergency.
How is Coronavirus Spread?
Peoplecan catch Covid-19 from others who have the virus. It is understood that the virus is highly infectious and moves from person to person in droplets from the nose or mouth which are spread when a person with Covid-19 coughs or exhales. In addition, the virus can survive for up to 72 hours out of the body on surfaces. People can catch Covid-19 if they breathe in the droplets or touch infected surfaces and then touch their eyes, nose or mouth. It is known that infected individuals who show no symptoms may still be able to pass on the virus, especially in the early stages of infection. This is described as asymptomatic spread.
What are the Symptoms?
The main symptoms of coronavirus infection are fever and high temperature, a new, continuous dry cough and/or loss or change to the sense of smell or taste. Other less common symptoms include aches and pains, nasal congestion, headache, tiredness and fatigue. Symptoms begin gradually and are usually mild. Most people (about 80%) recover from the disease without needing special treatment. A small percentage can become seriously ill and develop difficulty breathing. This is particularly dangerous for people with weakened immune systems, for older people, and for those with long-term conditions such as diabetes, cancer and chronic lung disease. Some domiciliary care service users will clearly be vulnerable to being seriously ill if they are infected by the virus.
This organisation will keep up to date with the latest public health and national government information about the risk of coronavirus in the UK, particularly with developments from new variants. The infection control lead for the organisation will maintain close links with local health protection teams and will be responsible for circulating essential information to staff and, where necessary, to service users and their families. They will also update the organisation’s management team. The organisation will comply fully with official advice, including Coronavirus (COVID-19): Provision of Home Care (updated November 2021), published by Public Health England. Infection Control and Prevention Procedures. This organisation believes that general adherence to high standards of infection prevention and control allied to vaccination are the best ways to prevent the person-to-person spread of pathogens such as coronavirus and maximise the safety of staff, service users and their families. To achieve this the organisation's infection control policies and procedures will be implemented in full, especially those related to effective hand hygiene, sanitisation and environmental cleaning. Care managers and supervisory staff should make sure that people:
• are fully vaccinated and receive boosters as recommended
• keep a safe distance from one another in social interactions that do not require close contact (such as when delivering personal care)
• wear face coverings in enclosed situations particularly where 2m physical distancing is difficult to maintain and where the regulations make their wearing compulsory
• cover their mouth and nose with a tissue or their sleeve (not their hands) when they cough or sneeze
• put used tissues in the bin immediately
• wash their hands with soap and water regularly for 20 seconds and use hand sanitiser gel (at least 60% alcohol) if soap and water are not available
• try to avoid close contact with people who are unwell
• avoid touching their eyes, nose, and mouth with unwashed hands
• clean and disinfect frequently touched objects and surfaces.
Staffshould comply fully with hand sanitisation policies and procedures. Managers will ensure that policies are supported by the provision of appropriate resources such as hand sanitiser gels that contain at least 60% alcohol for home care staff. The advice should be passed on to service users. It is important that care staff adhere to high standards of infection control practice while in services users’ homes and that they ask service users to do so too. Regular cleaning of frequently touched hard surfaces with a suitable disinfectant and cleanser should be carried out. This organisation will comply fully with all existing infection control and prevention guidance, including the Health and Social Care Act 2008: Code of Practice on the Prevention and Control of Infections
Covid-19 Public Health Restrictions
This organisation will comply fully with all official public health guidance and restrictions. The government response throughout the Covid-19 pandemic has been to take necessary public health action to limit transmission of the virus by imposing a series of restrictions. These have included:
• regional and national lockdowns requiring people to stay at home, including working from home wherever possible
• people observing “social distancing” and keeping at least 1m away from others not in the same household
• restrictions on travel, especially trips in and out of lockdownareas and international travel
• restrictions on gatherings and closures of places such as pubs, restaurants, cafes, schools and hairdressers
• special protections for the most vulnerable members of society
• wearing masks in public places and on public transport (a renewed requirement from 30 November 2021 following the threat of the new Omicron variant first identified in South Africa).
The first lockdown was imposed in March 2020 following the initial “first-wave” of infection. After a brief summer respite, a “second-wave” of infection swept through the UK at the end of 2020 as people moved indoors in colder weather and new more infectious Covid-19 variant strains emerged. NHS winter pressures exacerbated the situation and another national lockdown was announced from January 2021 following a dramatic increase in infection rates, hospitalisations and deaths. The lockdown was considered necessary despite the hopeful sign of vaccines becoming available and being rolled out across the country. In February 2021 the Government in England published a roadmap for coming out of the lockdown. The plan was based on falling virus transmission rates and a successful vaccination rollout which saw huge numbers of adults having their Covid-19 vaccines. Stage 4 of the roadmap applies from 19 July and represents a relaxation of formal legal restrictions, including social distancing. It was delayed from June by a rise in infection and hospitalisation rates driven by a new more transmissible Delta variant of the virus which has become established as the dominant strain worldwide. Despite this rise in infection the Government states that, with a significant proportion of the adult population already fully vaccinated, the balance of risks is such that a cautious return to near-normal life, without the majority of formal legal restrictions, is a reasonable position. However, people are still advised to be cautious, and are required to observe new measures put in place from end of November 2021 to prevent the spread of a new variant, Omicron. Full details are provided on the GOV.UK webpage, Coronavirus: How to Stay Safe and Help Prevent the Spread. Throughout the pandemic period it has been the policy of this organisation to ensure that all public health messages, including those relating to staying home and social distancing, are passed on to staff, service users and relatives. Therefore everyone knows what is permitted and what is not.
This organisation is aware that throughout the pandemic the Government has recommended a number of “Covid secure” measures for the workplace designed to protect staff and support social distancing at work. From 19 July 2021 Stage 4 of the lockdown easing roadmap applies and most official restrictions have been removed. Despite this, good practice recommendations still apply for employers who have a duty under health and safety law to carry out appropriate risk assessments and ensure the safety of staff and people using their services. In this organisation “Covid-secure” measures will be implemented in the domiciliary care office and in the way that care staff are asked to operate. These will be proportionate to any threat of virus transmission and informed by government guidance for employers, particularly:
• Working Safely During Coronavirus (COVID-19), published by the Department for Business, Energy & IndustrialStrategy
• Coronavirus (COVID-19): Working Safely, published by the Health & Safety Executive.
• reviewing and updating workplace risk assessments
• increasing the safety of agency offices by putting in place measures to reduce contact between people, such as rearranging desks and workstations, installing shields and adjusting office processes, etc
• allocating maximum occupancy limits to office areas
• increasing workplace cleaning and ventilation
• ensuring the provision of hand hygiene resources, including supplies of soaps and paper towels in toilets, sensor tap and toilet flushing systems, and the provision of hand sanitisers where needed
• creating “one-way” routes in corridors and limiting numbers ofpeople using toilets or rest rooms
• staggering office staff arrival and leaving times
• supporting office and care staff to “work from home” whereverpossible, reducing any need to have to attend offices or community bases to a minimum
• limiting “hot-desking” and the sharing of equipment
• reducing the need for face-to-face meetings by using digitalcommunication methods wherever possible
• reorganising training and recruitment processes to reduceface-to-face elements to a minimum• encouraging staff not to car share or use public transport at thecurrent time
• displaying appropriate Covid-19 safety signage.
Measures will be kept under review. Full consultation on Covid safety measures will beheld with staff representatives.
Staff Health and Self-isolation
Government strategy throughout the UK is to ask people to self-isolate in their homes where they have symptoms of Covid-19 infection or think that they might have the virus. Two sets of government guidance apply, both of which were updated in August 2021:
• Stay at Home: Guidance for Households with Possible or Confirmed Coronavirus (COVID-19) Infection (updated November 2021)
• Guidance for Contacts of People With Confirmed Coronavirus (COVID-19) Infection Who Do Not Live With the Person (updated November 2021).
Thefirst set of guidance applies to:
• people with symptoms that may be caused by Covid-19, including those who are waiting for a test
• people who have received a positive Covid-19 test result (whetheror not they have symptoms)
• people who currently live in the same household as someone withCovid-19 symptoms, or with someone who has tested positive for Covid-19.
Anyone in these categories is required to stay at home and self-isolate immediately. They could be fined if they do not. Those with symptoms of Covid-19, should arrange to have a PCR test as soon as possible. This applies even if they have received one or more doses of Covid-19 vaccine. It does not apply to those under 18 years 6 months of age. The isolation period is currently 10 full days from the date of the start of symptoms or from the date of a positive test result. Those living in the same household as someone with Covid-19 must stay at home and self-isolate. They should not come to work. The 10-day isolation period includes the day the first person in the household’s symptoms started.From 16 August individuals are not be required to self-isolate if they live in the same household as someone with Covid-19 and they are fully vaccinated or below the age of 18 years 6 months. In this respect fully vaccinated means being vaccinated with an MHRA approved Covid-19 vaccine in the UK and at least 14 days have passed since receiving the second dose. The second set of guidance is for people who have been notified by NHS Test andTrace that they are a contact of a person who has had a positive test result for Covid-19 and who is not from that person’s household. In such cases people are still required to self-isolate for 10 days from the date of notification unless they have been fully vaccinated against Covid-19. Theguidance includes a wide range of FAQs to help people decide how the rules apply in different situations. In this organisation staff who develop symptoms of Covid-19 must:
• not attend work if they develop symptoms while at home (off-duty) —in such cases they should notify their line manager immediately and follow thestay at home guidance
• put on a surgical face mask immediately if they develop symptoms while at work, inform their line manager and return home
• comply with all requests for testing.
This organisation will take all reasonable measures to prevent the transmission of the Covid-19 virus via its care staff, including:
• ensuring that all staff are aware of the requirement not to come to work when there is a risk that they may spread infection
• ensuring that care staff are supported to self-isolate in line with government guidance if they need to
• ensuring, where possible, that members of staff work with only anidentified cohort of clients — this includes staff who usually work on apart-time basis for multiple employers and agency staff.
The organisation is aware that the Government has provided an Infection Control Fund to support both residential and domiciliary adult social care providers in ensuring that self-isolating staff are fully paid while doing so. The organisation will liaise with the local authority in accessing the fund where it is available.
At the start of the pandemic the NHS identified individuals who were considered to be “high risk” from Covid-19 due to pre-existing health conditions. These were described as “clinically extremely vulnerable” and advised to “shield” and take special precautions to protect themselves from the virus. At the end of March 2021, the shielding scheme was paused as part of lockdown easing. From 19 July, Stage 4 of the lockdown easing roadmap, the Government advises that, at the very least, clinically extremely vulnerable people should follow the same guidance as everyone else. In addition, the Government suggests that individuals may choose to limit the close contact they have with those they do not usually meet, particularly when Covid-19 disease levels inthe general community are high. Guidance on Protecting People Who Are Clinically Extremely Vulnerable from COVID-19 (updated November 2021) provides the latest information for England Everyone identified as vulnerable should already have been offered a Covid-19 vaccine and will hopefully be fully vaccinated. Such individuals are also urged to access a booster vaccine in the autumn when available. Thisorganisation will comply with all applicable guidance to identify and protect individual service users and staff who are considered “high risk” from coronavirus. The organisation will work closely with GPs and healthcare providers and in collaboration with families and carers to ensure the safety of service users considered high-risk. It will also offer occupational health support as required for any staff who fall into the high-risk category.
Care Planning and Referrals
Duringthe pandemic crisis the organisation will keep service user care plans under constant review to ensure that their needs are being met. It will also carry out full risk assessments in relation to any new referrals in order to ensure that the prospective service users and their staff are kept safe from cross infection of the coronavirus. Vulnerable service users will be identified and plans will be put in place to ensure their safety. The organisation will work closely with relatives/carers and with care and health partners and charities/community support groups. Where necessary arrangements for mutual aid will be established with reference to our existing information sharing and adult safeguarding policies. Plans for mutual aid may be agreed which reduce the number of different people visiting a certain individual, especially those who are considered at risk or subject to shielding arrangements.
This organisation will follow relevant guidance on the care of people during the pandemic, including Coronavirus (COVID-19): Provision of Home Care (updated November 2021) published by PHE. Accordingto the guidance:
• home care workers are advised to report suspected cases of Covid-19 to their managers who should work with community partners, commissioners and the person involved to review their care needs
• the risk of virus transmission will be reduced by managers and staff working together to divide service users into “care groups” with a specific staff team allocated to provide care to each group (though this is no longer a formal recommendation on order to enable full workforce deployment particularly where there are staff shortages)
• this will include identifying extremely vulnerable service users as a specific group and allocating staff who only provide care for that group
• staff should work with other agencies as a part of agreed multi-agency care plans to reduce the numbers of people visiting extremely vulnerable and clinically vulnerable service users
• decisions about reallocating tasks or reducing visits to limit contacts with service users will be made with due consideration of the wishes and feelings of the service user, and unpaid carers in line with a personalised care approach
• risks will also be reduced by reducing contact between staff, including replacing face-to-face meetings with remote communications, and by staggering times of entry to community bases. In all cases care staff must follow infection control best practice, desanitising/washing hands frequently and using personal protective equipment (PPE) appropriately. Frequently touched surfaces should be cleaned regularly with household detergent and/or bleach. All care staff working in people’s homes will be supplied with stocks of PPE as well as alcohol hand sanitiser and surface wipes.
The care service will continue to apply all measures to keep people safe in line with its current policies and local authority safeguarding authority procedures. It will continue to alert the local authority to any safeguarding issue and notify CQC in line with its current notification requirements and procedures. The service will continue to exercise its Duty of Candour where it has made mistakes that have caused serious harm to its service users.
MentalCapacity and Deprivation of Liberty
The care service is aware of the implications of the current situation for it's service users who might lack mental capacity to understand the decisions that are being taken or to act in line with them. The service will do everything it can to ensure that it applies “best interests” principles in communicating with people without capacity and in taking the decisions that are required in line with the current public health requirements.
Personal Protective Equipment (PPE)
In this organisation, care staff should use all personal protective equipment (PPE) as directed in the organisation’s infection prevention and control policies. The organisation will also comply with the following Public Health England (PHE) guidance.
• PersonalProtective Equipment (PPE) — Resource for Care Workers Delivering DomiciliaryCare During Sustained COVID-19 Transmission in England
This organisation is aware that Personal Protective Equipment (PPE) — Resource for Care Workers Delivering Domiciliary Care During Sustained COVID-19 Transmission in England (updatedAugust 2021) provide guidance about periods when there is considered to be“sustained transmission” of the Covid-19 virus. This covers periods when the virus is assessed to be common in the community and care staff are likely to come into contact.In this organisation the use of PPE for infection control purposes will be informed by best practice guidance and subject to risk assessment supported by line managers and supervisors. Risk assessments will be regularly reviewed and will indicate the PPE to be used, largely with reference to the tasks that home care staff are carrying out. The organisation understands that specific recommendations for domiciliary care during sustained transmission periods are summarised in the guidance in two scenarios.
Table 1 provides PPE recommendations when within 2m of a client and carrying outdirect personal care or domestic duties. In these circumstances PHE recommendswearing:
• disposable gloves (vinyl, latex or nitrile)
• a disposable plastic apron
• a single-use fluid-repellent surgical mask (Type IIR)
• eye protection (where there is a risk of contact with body fluids).
The guidance applies to all direct personal care tasks and irrespective of whether the client has Covid-19 symptoms or has tested positive.
Table 2 provides PPE recommendations when more than 2m from a client and undertaking domestic duties and not delivering personal care. Here the recommendations are to wear disposable gloves (vinyl or nitrile) and either a Type I or II surgical mask or Type IIR mask. Eye protection is not considered necessary unless the client has had a positive Covid-19 test and is quarantining, or has respiratory symptoms. ThePHE guidance states that single-use PPE items such as gloves, aprons and fluid-repellent surgical masks (Type IIR) must be changed between each client. Reusable eye protection should be cleaned and decontaminated according to the manufacturer’s instructions. Any PPE should be changed if it becomes soiled, contaminated, damaged or uncomfortable to wear. Once masks are discarded they should never be reused. If eating or drinking staff are required to remove their mask, dispose of it and clean their hands. Once they have finished eating or drinking they should put on a new mask.All staff will be trained in the safe use of PPE, including how to put PPE on and take it off. Usage should be monitored by line managers/supervisors. Posters demonstrating PPE requirements and showing how to put PPE on and take it off will be displayed in the office and circulated to care staff. In this organisation the care management will keep the PPE guidelines under review and complete appropriate risk assessments. The organisation is aware that PHE recommends the general use of PPE during periods of “sustained transmission” of Covid-19 in the community regardless of whether clients have symptoms. The care service manager will make every effort to ensure that adequate stocks of appropriate PPE are maintained and that PPE is readily available for staff to use. Care staff should ensure that they have enough PPE (especially masks) to carry out their duties and change their mask between each client. Office areas will be organised so that care workers collecting PPE are able to remain at least 2m apart from office staff, for example, by having a designated area for collection and drop-off point for equipment.
The care service will continue to maintain its safe recruitment policies andprocedures in line with its registration requirements. In the event of it being unable to maintain its staffing complement and levels because of shortages caused by the current situation with staff sickness or having to self-isolate, it will follow the respective guidance produced by the CQC. Thiswill enable it, where necessary, to “fast track” its recruitment procedures, including DBS checks, in order to maintain staffing levels that keep service users safe and have their needs met as well as enabling it to employ additional staff that enables it to cope with the additional burdens created by the coronavirus situation and any outbreaks of Covid-19 illnesses.
Induction and Training
This care service will keep all risk assessments of its training arrangements under review. Assessments will include the running of induction training programmes for Care Certificate. Face-to-face training that is not deemed to be a priority at the current time will be cancelled or rescheduled. Where possible face-to-face training will be replacedby online “e-learning” methods. This will include “blended”learning where theory elements are carried out online prior to attending, thus reducing the amount of face-to-face time. Priority face-to-face training elements that cannot be replaced with online alternatives will proceed with suitable Covid-safe risk mitigation procedures in place, including:
• all attending staff to wear masks, to observe social distancing,and to observe hand and respiratory hygiene guidelines
• all training venues to be set up to enable social distancing,including during arrival and leaving
• all venues to be ventilated and subject to regular cleaning
• no sharing of equipment
• no staff to attend who are feeling unwell
• no refreshments.
Inductionof new staff who are new to care work will still follow a Care Certificate pathway but with an expectation that the usual time period, particularly for work-based assessments, might need to be extended and the programme developed more incrementally. Induction of new staff with experience of care work will focus on ensuring they are competent to carry out their roles and tasks in the current circumstances by ensuring that they implement key policies and procedures regarding service users’ care, and ensuring that it is safe and effective. Much of the induction for any new staff will be carried out through workplace instruction, support, supervision and guidance from management and experienced staff. The care service’s “safe to leave policy” will continue to apply. No new staff member will be allowed to work completely on their own without sufficient evidence that it is safe for them to do so.
Testing and Tracing
This organisation will support staff and their families to access coronavirus testing in line with the respective UK countries policies. All frontline social care staff are classified as “essential workers” and are eligible for such tests. Those who are self-isolating can book a test directly, selecting a regional test site drive-through appointment or a home test kit. Employers can book tests through an employer referral test booking route. This organisation is aware that access to testing has been progressively increased throughout the pandemic and that the COVID-19: OurAction Plan for Adult Social Care makes the ramping up of testing for care workers and service users a key priority. The organisation will take all reasonable steps to support this strategy and comply with local and national testing programmes. This organisation will fully support testing and tracing. Further information can befound from the online document, NHS Test and Trace: What to Do if You are Contacted.
This organisation requires staff to comply with any current official government advice and to inform their line manager wherever the guidance may apply to them, especially guidance relating to any need to self-quarantine after international travel. Latest travel advice can be found on the GOV.UK Government website.
This organisation will support all staff and service users to be vaccinated against Covid-19 and will implement the mandatory vaccination requirement for all health and domiciliary care staff that comes into effect from April 2022. A number of safe and effective vaccines have so far been approved for use in theUK by the regulator, the Medicines and Healthcare products Regulatory Agency. Theapproved vaccines are:
• the Pfizer/BioNTech vaccine
• the AstraZeneca/Oxford University vaccine
• the Moderna vaccine (not immediately available in the UK).
The policy of the organisation is that all of our adult social care staff and service users should have by now been offered vaccination, and those that have not yet been fully vaccinated must be so before April 2022. The organisation is aware that a strategy setting out priority groups for the vaccination roll-out was developed in December 2020 by the Joint Committee on Vaccination and Immunisation, the expert advisory group for vaccination in the UK. According tothe strategy, Advice on Priority Groups for COVID-19 Vaccination, the most vulnerable were prioritised in Phase 1 of the vaccination programme. In addition to the most vulnerable, Phase 1 also covered all health and social care staff and all adults over 50. It was completed at the start of the summer 2021. Those remaining adults under 50 were covered in Phase 2 which was completed by the end of the summer. Many have now received a booster jab. Adult social care staff were targeted for vaccination early in the campaign, many being offered the Pfizer/BioNTech vaccine delivered from a limited number of hospital hubs. This was because the vaccine needed to be kept very cold. The AZand Moderna vaccines are easier to deploy and have been rolled out through hospitals, community vaccination centres, GP practices and “mass vaccination”hubs. Allof the currently used vaccines require two injections. People are not fully vaccinated until they have had both jabs. The vaccination plan supports the JCVI strategy for prioritising the first dose of the vaccines. It states that prioritising the first doses of vaccine for as many people as possible will protect the greatest number of people overall in the shortest possible time. The care manager will be responsible for supporting the vaccination of staff and service users in collaboration with local GPs and local vaccine delivery teams where necessary. Every effort should be made to facilitate and support access to vaccination for all staff and clients. Full records will be kept of vaccine status. These should be maintained once vaccination becomes mandatory, using evidence outlined in government guidance and which makes use of the NHS vaccine passport scheme. Service user care plans continue to be subject to review and those who still require support to access vaccination will be provided with help from home care staff. This organisation will fully support the roll-out of the third-dose Covid-booster vaccination. It is understood that this campaign is run in parallel to the annual flu jab and be designed to ensure that vulnerable people are given the maximum protection when both the Covid and flu viruses are circulating together through the winter. Business Continuity Procedures and Pandemic Recovery Planning. In addition to the organisation’s general business continuity and recovery planning policies, the organisation recognises the need to have a separate pandemic recovery plan and procedure. This is because a general continuityrecovery plan focuses on a short-term recovery programme. In contrast, theeffects of the pandemic could last many months. In this organisation the following contingency measures will be implemented.
• A communications strategy will be developed to ensure that staff, service users and their families are provided with up-to-date and accurate information on the status of the pandemic and on the organisation’s response.
• Every effort will be made to provide the information to service users in a format that they can understand. The organisation recognises that the current crisis will be upsetting and worrying for service users andrelatives.
• Information will be provided to staff via e-mail and through text where practical and unnecessary face-to-face meetings will be cancelled — where meetings are held social distancing will be observed.
• Training will make use of online e-learning and other electronic forms where possible — any face-to-face training will be conducting conforming to social distancing rules.
• The organisation’s leave and absence policies will be continuously reviewed as the status of the pandemic changes, for instance, it may become necessary to cancel leave in case of serious short-staffing.
• Staff will be informed of any additional measures to limit the spread of disease in a pandemic situation — this might include:
– avoiding unnecessary travel
– cancellation of face-to-face meetings
– plans to reduce the impact of absentees
– working from home where possible for managers and office staff
– systems to lessen the impact of supply chain disruption.
• Essential services will be prioritised.
• Advice will be provided for vulnerable service users on steps to take to protect themselves.
• Care plans will be reviewed to identify service users most at risk in case of service disruption.
• As a contingency measure, staff will be cross-trained in various functions to ensure that adequate cover is provided in different roles should sickness rates rise.
• Staff who perform roles that can be done from home will be encouraged to. The management of the organisation will link with any local resilience forums relevant to health and social care provision. Line managers and supervisors will be responsible for ensuring that staff understand the organisation’s pandemic recovery plan policy and procedure. Staff should familiarise themselves with the procedure and should speak to their line manager if they have any questions or concerns. The procedure aims to ensure that the organisation will be able to continue to provide care to its service users during any disruption caused by a pandemic.
Corrective Preventive Action
In an effort to ensure continual improvement, Key 2 Care Ltd engages incorrective and preventive action to discover, investigate, and correct nonconformances related to Key 2 Care Ltd services, its processes, policies, and the company’s quality system.
Business Continuty and Emergency Planning
Protective Clothing and Equipment
Duty of Candour
Corrective Preventive Action Procedure
Managers and staff will be kept up to date with relevant local and national plans andrevisions, as appropriate, in order to respond in an effective and efficientmanner.
This policy will be reviewed by the Business Manager
15 December 2021
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